Epstein Secrets

be adjusted pursuant to Section 2.3. "Equivalent Heritage Points Deficit" means, with respect to a Principal Group, as of immediately prior to any Exchange, the excess (if any) of the number of 4 I ." CSI. 144-7-7441'9 1/octi: US1:107703119t 15 EFTA00808228 Equivalent Heritage Points of such Princ

ssification, recapitalization, merger, consolidation or other reorganization. "APO Corp." means APO Corp., a Delaware corporation. "APO LLC" means APO Asset Co., LLC, a Delaware limited liability company. "Apollo" means Apollo Global Management, LLC. "Apollo Employer" means Apollo or any successor thereto.

vable Agreement) made with respect to the Transaction result in additional step ups in tax basis and in additional future tax deductions. A further Exchange (as defined in Section 1.01 of the Tax Receivable I Unless otherwise specified. all references to "Section" are to the Internal Revenue Code of 1986

s. The Transaction On July 13, 2007, Apollo Global Management, LLC contributed to APO Corp., a corporation for US Federal income tax purposes, and APO Asset Co., an entity that has elected to be disregarded for US Federal income tax purposes, (collectively, the "Intermediate Holdings Companies") $1.2 billio

shall be adjusted pursuant to Section "Equivalent Heritage Points Deficit" means, with respect to a Principal Group, as of immediately prior to any Exchange, the excess (if any) of the number of Equivalent Heritage Points of such Principal Group over the Pecuniary Interest in the Heritage Points of such

merger, consolidation or other reorganization. NYI:16116459.16 EFTA00623301 "APO Corp." means APO Corp., a Delaware corporation. "APO LLC" means APO Asset Co., LLC, a Delaware limited liability company. "Apollo" means Apollo Global Management, LLC. "Apollo Employer" means Apollo or any successor thereto.

be adjusted pursuant to Section 2.3. "Equivalent Heritage Points Deficit" means, with respect to a Principal Group, as of immediately prior to any Exchange, the excess (if any) of the number of Equivalent Heritage Points of such Principal Group over the Pecuniary Interest in the Heritage Points of such

ssification, recapitalization, merger, consolidation or other reorganization. "APO Corp." means APO Corp., a Delaware corporation. "APO LLC" means APO Asset Co., LLC, a Delaware limited liability company. "Apollo" means Apollo Global Management, LLC. "Apollo Employer" means Apollo or any successor thereto.